Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The Tribunal rejected the Transfer Pricing Officer's benchmarking based on Indian bank rates since the Associated Enterprise obtained a loan from a Saudi Arabian bank. Considering the consistent approach of coordinate Benches, the Tribunal directed the Assessing Officer to restrict the arm's length price adjustment to 0.5% for the corporate guarantee fees.
The Appellate Tribunal partly allowed the assessee's appeal concerning the transfer pricing adjustment on corporate guarantee fees for international transactions. The Tribunal rejected the Transfer Pricing Officer's benchmarking based on Indian bank rates since the Associated Enterprise obtained a loan from a Saudi Arabian bank. Considering the consistent approach of coordinate Benches, the Tribunal directed the Assessing Officer to restrict the arm's length price adjustment to 0.5% for the corporate guarantee fees.
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